Morrison-Knudsen Company, Inc. v. The United States

427 F.2d 1181, 192 Ct. Cl. 410, 1970 U.S. Ct. Cl. LEXIS 136
CourtUnited States Court of Claims
DecidedJune 12, 1970
Docket3-69
StatusPublished
Cited by7 cases

This text of 427 F.2d 1181 (Morrison-Knudsen Company, Inc. v. The United States) is published on Counsel Stack Legal Research, covering United States Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morrison-Knudsen Company, Inc. v. The United States, 427 F.2d 1181, 192 Ct. Cl. 410, 1970 U.S. Ct. Cl. LEXIS 136 (cc 1970).

Opinion

ON PLAINTIFF’S MOTION AND DEFENDANT’S CROSS-MOTION FOR SUMMARY JUDGMENT

DAVIS, Judge.

The Social Security Amendments of 1965, Public Law 89-97, 79 Stat. 286 (enacted July 30, 1965), provided that, as of January 1, 1966, there would be a rise in the rates of social security taxes, as well as in the base for the rates. That increase is relevant to this ease because plaintiff, Morrison-Knudsen Company, Inc., claims that under its construction contract with the Government it is entitled to an upward adjustment in price on account of this statutory addition to social security taxes. The fixed-price contract, entered into the summer of 1965 after formal advertising, was for certain work at the National Aeronautics and Space Administration Merritt Island Launch Area. One of the agreement’s articles (Clause 26)- — a standard provision, headed “Federal, State and Local Taxes 1 — declares: “with respect to any Federal excise tax or duty on the transactions or property covered by this contract, if a statute * * * takes effect after the contract date, and—

(1) results in the Contractor being required to pay or bear the burden of any such Federal excise tax or duty or increase in the rate thereof which would not otherwise have been payable on such transactions or property, the *1182 contract- price shall be increased by the amount of such tax or duty or rate increase, provided the Contractor warrants in writing that no amount for such newly imposed Federal excise tax or duty or rate increase was included in the contract price as a contingency reserve or otherwise; * * ” 2

Acting under this clause, plaintiff gave notice to the defendant at the end of May 1966, that it had incurred and would continue to incur additional costs because of the increase on January 1, 1966, in social security taxes levied by the Social Security Amendments of 1965, and that it was therefore eligible for an upward adjustment in price. The letter warranted that no amount for such a tax increase had been included in the contract price. This claim was denied by the contracting officer on the legal ground that an increase in social security taxes is not covered by the contract provision. An appeal to the Corps of Engineers Board of Contract Appeals was dismissed on the Government’s motion. In view of this action, defendant expressly agrees, for this particular case, that the contractor can properly proceed in court without regard to the contract disputes procedure. Each party asks for summary judgment.

For an increase in contract price to be allowable under Clause 26, supra,, on account of an upward revision in federal tax rates, the plaintiff must show that (1) an excise tax is involved; (2) this excise is “on the transactions or property covered by this contract”; (3) the *1183 tax increase took effect after the “contract date”; (4) the contractor was required to pay or bear the burden of the increase, and (5) no amount “for such newly imposed Federal excise tax * * * increase was included in the contract price as a contingency reserve or otherwise.”

Four of these five factors are not seriously in question at this stage of the litigation. It is indisputable that the increase imposed by the Social Security Amendments of 1965 on employers was a federal excise tax. The Act specifically so characterizes it (§ 321(e), 79 Stat. 396), and the pertinent holdings are that social security taxes levied on employers are excises. See Abney v. Campbell, 206 F.2d 836 (C.A.5, 1953); Blake Constr. Co., GSBCA No. 1289, 65-1 BCA P557 (1964). There is also no doubt that the tax increase took effect after the “contract date.” That term is defined by the contract clause (see note 2, swpra) as “the date set for bid opening.” In this case, that day was July 27, 1965. The Act became law on July 30th, and the increase involved here did not take effect until January 1, 1966. As for plaintiff’s carrying the burden of the increase, defendant does not contest that fact. The last factor, the warranty of non-inclusion in the contract price of any amount for the tax increase, was covered by Morrison-Knudsen’s original letter of demand, and is repeated in an affidavit filed on the current motions; by these documents, plaintiff has made at least a prima facie case on this point. 3

The only real question before us is whether the 1966 social security tax increase was “on the transactions or property covered by this contract.” The area of dispute is reduced even further since plaintiff agrees that the tax is not on “property.” The focus falls, therefore, on the meaning of “transactions * * * covered by this contract,” as related to federal social security taxation. Much exegetical energy can be expended on this problem, especially when fueled by a trace of metaphysics. The Government insists that, while the word “transaction” necessarily connotes action or movement, the social security tax is placed solely on a static state of being, the relationship of employer and employee. Plaintiff’s response is that the furnishing, hiring, and employment of labor is an integral part of the performance required by this construction contract, 4 and, accordingly, that employer-employee relationships necessarily constitute “transactions * * * covered by this contract.” Though such purely analytic guides are of some aid, we .think that the decisive help comes from three other inter-related sources: (i) the general purpose of the contract clause; (ii) the history of these clauses in federal procurement; and (iii) the canon relating to the Government’s responsibility for its own contractual ambiguities. Each of these signs points in the same direction— toward upholding the contractor’s viewpoint.

For federal excise taxes, the self-evident purpose of the contract clause— its general goal — is to make sure that bidders and contractors do not load their bids and prices with reserves or contingencies for the later imposition of, or increases in, such taxes. Bidders and contractors are to be encouraged to depend upon a price adjustment if they subsequently find themselves forced to pay higher taxes, rather than to seek to protect themselves in advance by raising their prices to cover the mere possibility of a tax increase. This general purpose seems to us to call for a liberal inter *1184 pretation of the coverage of the clause, once it is clear, as here, that a federal excise tax is involved. It would deter, rather than advance, the over-all aim of guarding against the unnecessary inflation of contingency reserves to give a niggardly, technical or too-finely-reasoned interpretation to the words “transactions or property covered by this contract.” This is broad, ordinary, language and it should be given a broad, ordinary, and common-sensieal reading so that bidders and contractors will not continue to load their prices with contingencies, for fear that some federal excise tax might later be held, by the type of refined linguistic parsing defendant uses here, not to be reached by the adjustment provision.

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Bluebook (online)
427 F.2d 1181, 192 Ct. Cl. 410, 1970 U.S. Ct. Cl. LEXIS 136, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morrison-knudsen-company-inc-v-the-united-states-cc-1970.